Offer of Composition from Singapore Customs

After a long-drawn investigation, OSH secured a settlement of the matter for the client, a large e-commerce logistics and procurement provider, by way of an offer of composition from the Singapore Customs. When the investigation first commenced via a surprise raid conducted by the Singapore Customs, the directors of the client were potentially faced with personal liability for the Company’s alleged wrongful reporting and under-declaration of the total value of goods imported into Singapore over the span of 4 years.

The matter was complicated as a large part of the inaccurate reporting and declarations were a result of errant freight forwarders. However, such did not detract from the client’s liability as the named importer of the goods. From a strict legal standpoint, the client was wholly liable for the under-declaration and payment of import GST. The matter was further complicated as the client had failed to put in place proper procedures for the accounting and declaration from the start of its operations and when business grew, the systems failed. In the absence of full and accurate records, there was a huge dispute as to the actual amounts of additional import GST payable.

Through protracted negotiations with the Singapore Customs and various proposals from the team as to the most appropriate proxies to use for the computation of the import GST underpaid, an amicable settlement was reached with no charges issued and less than usual penalties imposed.

For more information, please contact Joanne Khoo at or +65 6804 7568.

*Image source: Singapore Customs